Lugen Horizon – Strategic Consulting

Last Updated: September 2026

1. Introduction

LUGEN HORIZON S.A. (“LUGEN”, “we”, “us” or “our”) respects the privacy of individuals who visit our website, contact us, request information, or otherwise interact with our services.

This Privacy Policy explains how LUGEN may collect, use, store, disclose and protect personal information obtained through our website, communication channels, enquiry forms, investment and business opportunities, and other interactions with us.

By using our website or voluntarily providing personal information to LUGEN, you acknowledge that you have read and understood this Privacy Policy.

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2. Data Controller

The entity responsible for the processing of personal information covered by this Privacy Policy is:

LUGEN HORIZON S.A.
Vía España 1280, Edificio Orión, Suite 7D
Panamá, República de Panamá

Email: info@lugenhorizon.com

LUGEN may operate through third-party service providers and business partners in connection with its website, communications, services and activities. Where such parties process personal information on behalf of LUGEN, they may do so only for legitimate and authorised purposes.

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3. Information We May Collect

Depending on how you interact with LUGEN, we may collect information that you voluntarily provide, including:

• full name;
• email address;
• telephone number;
• WhatsApp contact information;
• country or geographic area of interest;
• business or professional information;
• areas of investment or business interest;
• investment preferences;
• indicative investment range or budget;
• information concerning a project, company, business opportunity or partnership;
• information contained in enquiries, messages or other communications;
• any other information that you voluntarily provide to us.

The information requested may vary depending on the nature of your enquiry or the service, opportunity or relationship concerned. LUGEN will seek to collect information that is reasonably relevant to the purpose for which it is requested.

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4. Information Collected Through Our Website

When you visit or interact with our website, certain technical information may be collected automatically, depending on the website configuration and technologies in use. This may include:

• IP address;
• browser type and version;
• device type;
• operating system;
• approximate location derived from technical information;
• pages visited;
• referring website;
• date and time of access;
• interaction with website features;
• technical, diagnostic and security information.

This information may be collected through server logs, cookies, pixels, analytics technologies or similar technologies where applicable.

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5. How We Use Personal Information

LUGEN may use personal information for purposes including:

• responding to enquiries and requests;
• communicating with individuals who contact LUGEN;
• providing information about LUGEN, its services, projects and opportunities;
• providing presentations and information concerning investment opportunities;
• evaluating potential business relationships;
• communicating with prospective investors, partners, clients, professionals and business contacts;
• understanding users’ interests and requirements;
• managing enquiries and business relationships;
• improving our website, services and user experience;
• operating, maintaining and securing our website and systems;
• preventing fraud, abuse or unauthorised activity;
• maintaining appropriate business and administrative records;
• complying with applicable legal and regulatory requirements;
• developing and introducing new services, opportunities, communication channels and website features;
• measuring and improving our communications, marketing and digital activities where applicable.

Personal information will not knowingly be used for purposes that are materially incompatible with the purpose for which it was originally collected without providing any additional information or obtaining any consent that may be required.

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6. Investment and Business Enquiries

LUGEN may present, evaluate, structure, develop, introduce or facilitate access to investment opportunities, business projects, partnerships and other commercial opportunities.

If you request information regarding an investment or business opportunity, LUGEN may request additional information that is reasonably relevant to your enquiry. Depending on the nature of the opportunity, this may include:

• investment interests;
• preferred geographic markets;
• investment range or budget;
• professional or business background;
• areas of expertise;
• business objectives;
• project interests;
• other information voluntarily provided by you.

Providing information to LUGEN does not itself constitute an investment commitment, offer, acceptance, contractual relationship or guarantee of access to any investment opportunity. Specific opportunities may be subject to separate documentation, eligibility requirements, due diligence, availability and applicable terms.

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7. Contact Forms and Communications

Information submitted through forms or other communication channels may be used to:

• respond to your request;
• provide requested information;
• contact you regarding the subject of your enquiry;
• provide additional information relevant to your enquiry;
• evaluate potential business, investment or partnership relationships;
• maintain records of communications and enquiries.

Where appropriate, LUGEN may contact you by email, telephone, WhatsApp or other communication channels that you have provided or requested.

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8. WhatsApp and Third-Party Communication Services

LUGEN may provide WhatsApp Business or other communication channels for direct contact.

If you choose to contact LUGEN through WhatsApp or another third-party communication service, information exchanged through that service may include your name, telephone number, messages and other information that you voluntarily provide.

The use of third-party communication services is also subject to the privacy policies and terms of those providers. LUGEN does not control the privacy practices, security systems or processing activities of third-party communication platforms.

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9. Marketing and Commercial Communications

LUGEN may from time to time communicate information concerning:

• investment opportunities;
• projects;
• business opportunities;
• services;
• partnerships;
• events;
• relevant developments;
• other information related to LUGEN’s activities.

Where consent is required for a particular form of marketing communication, LUGEN will seek the appropriate consent. You may request that LUGEN stop sending promotional or marketing communications by contacting us at info@lugenhorizon.com.

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10. Cookies, Analytics and Similar Technologies

LUGEN may use cookies and similar technologies to support the operation, security, functionality and improvement of the website. Depending on the website configuration, these technologies may be used for purposes including:

• website functionality;
• security;
• remembering preferences;
• analytics and performance measurement;
• understanding website usage;
• improving user experience;
• measuring marketing activities;
• supporting advertising or communication activities.

LUGEN may introduce or change analytics, advertising, measurement, security or other digital technologies as its website and business activities evolve. Where applicable, users will be provided with appropriate information and consent mechanisms before non-essential technologies are used where such consent is required.

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11. Third-Party Service Providers

LUGEN may use third-party service providers to support its activities and website operations. These providers may include services relating to:

• website hosting and infrastructure;
• domain and website management;
• email and communications;
• forms and enquiry management;
• customer relationship management;
• cloud storage;
• analytics;
• advertising and marketing;
• cybersecurity;
• technical support;
• payment or administrative services where applicable.

Third-party providers may process personal information only to the extent reasonably necessary to provide their services or otherwise as permitted by applicable law. LUGEN may change or introduce service providers as its operations develop.

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12. Sharing of Personal Information

LUGEN does not sell personal information as a business practice.

Personal information may be shared where reasonably necessary with:

• authorised employees or representatives of LUGEN;
• service providers supporting LUGEN’s operations;
• professional advisers;
• legal, regulatory or governmental authorities where required or permitted;
• business partners or counterparties involved in a potential transaction or business relationship, where appropriate;
• other parties where you have requested or authorised the disclosure;
• other recipients where disclosure is reasonably necessary for legitimate business purposes and permitted by applicable law.

LUGEN seeks to limit disclosure to information reasonably necessary for the relevant purpose.

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13. International Processing and Transfers

LUGEN operates in an international environment and may use service providers, partners or infrastructure located in different countries. As a result, personal information may be processed, stored or transferred across borders.

Where personal information is transferred to another jurisdiction, LUGEN will seek to apply appropriate safeguards and comply with applicable requirements relating to international data transfers.

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14. Data Security

LUGEN takes reasonable technical and organisational measures designed to protect personal information against unauthorised access, misuse, loss, alteration or disclosure. These measures may include appropriate access controls, security procedures, technical safeguards and limitations on access to personal information.

However, no website, electronic transmission or storage system can be guaranteed to be completely secure. If LUGEN becomes aware of a personal information security incident requiring action or notification under applicable requirements, LUGEN will take the appropriate steps.

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15. Data Retention

LUGEN may retain personal information for as long as reasonably necessary for the purposes for which it was collected, including:

• responding to enquiries;
• managing business relationships;
• evaluating investment or partnership opportunities;
• maintaining business records;
• complying with legal, regulatory, accounting or administrative obligations;
• resolving disputes;
• protecting LUGEN’s rights and interests.

Retention periods may vary depending on the nature and purpose of the information. When information is no longer reasonably required, LUGEN may delete, anonymise or securely dispose of it, subject to applicable retention obligations.

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16. Your Privacy Rights

Depending on the applicable law and circumstances, individuals may have rights concerning their personal information, including the right to:

• request access to personal information held by LUGEN;
• request correction of inaccurate or incomplete information;
• request cancellation or deletion where applicable;
• object to certain processing;
• request information about how personal information is processed;
• withdraw consent where processing is based on consent;
• request portability of personal information where applicable.

To exercise a privacy right or ask a question about the processing of your personal information, contact: info@lugenhorizon.com

LUGEN may take reasonable steps to verify the identity of the person making a request before providing access to or modifying personal information.

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17. Consent and Withdrawal

Where processing is based on consent, consent may be withdrawn by contacting LUGEN at: info@lugenhorizon.com

Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal. Certain information may nevertheless need to be retained where necessary for legal, regulatory, contractual, security or legitimate business purposes.

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18. Children’s Privacy

The LUGEN website and services are not intended to knowingly collect personal information from children. If you believe that a child has provided personal information to LUGEN, please contact us at info@lugenhorizon.com so that we can review the matter and take appropriate action.

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19. Third-Party Websites

The LUGEN website may contain links to third-party websites, platforms or services. LUGEN is not responsible for the privacy practices, content, security or policies of third-party websites. Users are encouraged to review the privacy policies of third-party websites before providing personal information to them.

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20. Future Services, Features and Data Collection

LUGEN is an evolving international business platform and may introduce new services, investment opportunities, partnerships, communication channels, website features, forms, questionnaires, technologies or other digital services from time to time.

As LUGEN develops, additional information may be requested where reasonably necessary for a particular service, opportunity, business relationship or enquiry. Such information may include, where relevant:

• investment preferences;
• investment range or budget;
• geographic interests;
• professional or business information;
• project or sector interests;
• partnership requirements;
• other information voluntarily provided by the user.

Where new activities involve additional processing of personal information, LUGEN may update this Privacy Policy and provide any additional information or consent mechanism required by applicable law.

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21. Automated Decision-Making

LUGEN does not currently intend to make decisions producing significant legal or similarly significant effects on individuals solely through automated processing of personal information. If this changes in the future, LUGEN will provide appropriate information and safeguards where required by applicable law.

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22. Changes to This Privacy Policy

LUGEN may update this Privacy Policy from time to time to reflect:

• changes in our services;
• new investment or business activities;
• new website functionality;
• changes in technology;
• changes in communication or marketing practices;
• changes in applicable requirements.

The latest version will be published on this website and identified by its “Last Updated” date. We encourage users to review this Privacy Policy periodically.

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23. Contact Us

For questions, requests or concerns regarding this Privacy Policy or the handling of personal information, please contact:

LUGEN HORIZON S.A.
Vía España 1280, Edificio Orión, Suite 7D
Panamá, República de Panamá

Email: info@lugenhorizon.com

WhatsApp: through the WhatsApp Business contact available on the LUGEN website.

© 2026 LUGEN HORIZON S.A. All rights reserved.

Last Updated: September 2026

1. Introduction

Welcome to the website of LUGEN HORIZON S.A. (“LUGEN”, “we”, “us” or “our”).

These Terms & Conditions (“Terms”) govern your access to and use of the LUGEN website, including its content, investment-related information, business opportunities, enquiry forms, presentations and communication channels.

By accessing or using this website, you acknowledge that you have read, understood and agree to be bound by these Terms. If you do not agree with these Terms, please do not use the website.

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2. About LUGEN

LUGEN HORIZON S.A. operates an international business and investment platform focused on investment opportunities, business development, strategic partnerships, projects and related activities.

LUGEN may present information concerning opportunities, projects, businesses, markets, assets, partnerships and other commercial activities through its website and other communication channels. The information presented on the website is provided for general informational purposes and may change over time.

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3. Use of the Website

You may use this website for lawful purposes and in accordance with these Terms. You agree not to:

• use the website for any unlawful or fraudulent purpose;
• attempt to gain unauthorised access to the website or its systems;
• interfere with the operation or security of the website;
• copy, reproduce, distribute or exploit website content without appropriate permission;
• use automated systems to extract or collect website content without authorisation;
• impersonate another person or entity;
• submit false, misleading or fraudulent information;
• use information obtained from the website in a manner that violates applicable laws or regulations.

LUGEN may restrict or terminate access to the website where reasonably necessary to protect its systems, users, business interests or legal rights.

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4. Website Content

The content published on the LUGEN website may include:

• descriptions of projects;
• investment opportunities;
• market information;
• business concepts;
• financial or commercial information;
• photographs and visual materials;
• presentations;
• estimates, projections or illustrative figures;
• general business information;
• information provided by third parties or project partners.

LUGEN seeks to present information accurately and in good faith. However, information may change, become outdated or depend on information received from third parties. LUGEN does not guarantee that all information available on the website will always be complete, accurate, current or error-free.

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5. Investment Opportunities

Certain areas of the website may describe potential investment opportunities, projects, partnerships or commercial opportunities.

Information regarding an opportunity is provided for preliminary informational purposes and does not, by itself, constitute:

• an offer to sell or purchase securities;
• a solicitation to invest;
• investment advice;
• financial advice;
• a recommendation to enter into a transaction;
• a guarantee of availability;
• a guarantee of returns;
• a binding commitment by LUGEN;
• a contractual offer or acceptance.

Any actual investment or commercial transaction will be subject to separate documentation, applicable terms, due diligence, eligibility requirements, availability and any other requirements applicable to the relevant opportunity.

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6. No Investment Advice

Information provided by LUGEN through the website, presentations, communications or other materials is not intended to constitute personalised investment, financial, legal, tax or accounting advice.

Information about an opportunity should not be interpreted as a recommendation that a particular investment, project, asset, transaction or strategy is suitable for you.

You are responsible for conducting your own evaluation and obtaining independent professional advice where appropriate before making an investment or business decision.

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7. Investment Risks

Investments and business opportunities may involve substantial risks, including the possible loss of some or all of the capital invested.

Past performance, historical information, projected returns, estimated yields, ROI figures, forecasts or other financial information presented by LUGEN are not guarantees of future results.

Any projections, estimates or illustrative financial information are subject to assumptions, market conditions and other factors that may change. Actual results may differ materially from any projections or estimates.

You should consider your own financial circumstances, objectives, risk tolerance and professional advice before making an investment decision.

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8. No Guarantee of Returns

Where the website or related materials refer to ROI, yields, appreciation, projected income, returns or other financial outcomes, such information is provided for illustrative or informational purposes unless expressly stated otherwise in separate binding documentation.

No statement on the website should be understood as a guarantee that a particular return, profit, yield or financial result will be achieved. Investment outcomes may be affected by market conditions, operating performance, costs, taxes, regulations, currency movements, economic conditions and other factors.

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9. Investment Presentations and Materials

LUGEN may make presentations, documents, data rooms or other materials available to users who request information about particular opportunities.

Access to such materials does not constitute an offer, acceptance, investment commitment or guarantee of participation. Additional information may be provided only after appropriate enquiries, qualification, due diligence or other processes where considered appropriate by LUGEN.

LUGEN may modify, withdraw or discontinue an opportunity or related materials at any time without prior notice.

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10. Requests for Information

Submitting a form, requesting a presentation, contacting LUGEN through WhatsApp or email, or otherwise expressing interest in an opportunity does not create a contractual relationship or investment commitment.

LUGEN may contact you following an enquiry to provide additional information or discuss the relevant opportunity. LUGEN may decide, at its discretion and subject to applicable requirements, whether to provide additional information or proceed with discussions.

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11. Eligibility

Certain investment opportunities, projects or services may only be available to individuals or entities meeting specific eligibility, geographic, financial, professional or legal requirements.

LUGEN may request additional information where reasonably necessary to determine whether an individual or entity may participate in a particular opportunity or business relationship. Access to information on the website does not guarantee eligibility for any particular opportunity.

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12. Third-Party Information

Certain information displayed by LUGEN may originate from third parties, project partners, consultants, service providers, public sources or other external sources.

While LUGEN may review information before publication, LUGEN does not guarantee the accuracy or completeness of information supplied by third parties. Third-party information remains subject to the responsibility and terms of the relevant third party.

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13. Intellectual Property

Unless otherwise indicated, the website and its contents are owned by or licensed to LUGEN. This includes, without limitation:

• the LUGEN name and brand;
• logos;
• visual identity;
• website design;
• text;
• graphics;
• photographs;
• presentations;
• documents;
• layouts;
• original materials;
• other intellectual property appearing on the website.

You may access and use website content for personal and legitimate informational purposes. You may not reproduce, modify, distribute, publish, sell, license, commercially exploit or create derivative works from LUGEN content without prior written permission, except where permitted by applicable law.

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14. Confidentiality of Materials

Certain presentations, documents or information provided by LUGEN may be designated as confidential or intended solely for the recipient.

Where information is expressly identified as confidential, you agree not to disclose, reproduce or distribute it to third parties without prior written permission from LUGEN, except where disclosure is required by law. Additional confidentiality obligations may apply to specific opportunities or business relationships.

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15. Third-Party Websites and Services

The LUGEN website may contain links to third-party websites, platforms or services. These links are provided for convenience or informational purposes.

LUGEN does not control and is not responsible for the content, availability, security, privacy practices or terms of third-party websites or services. Your use of third-party websites and services is subject to their respective terms and policies.

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16. Website Availability

LUGEN aims to maintain the website and its services in a reliable manner but does not guarantee that the website will always be available, uninterrupted, secure or error-free.

LUGEN may modify, suspend, discontinue or restrict any part of the website at any time. LUGEN may also perform maintenance, updates or technical changes that temporarily affect availability.

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17. Information Security

You are responsible for maintaining the security of any credentials, access information or confidential materials provided to you. You must notify LUGEN if you become aware of unauthorised access to your account, information or materials.

LUGEN will take reasonable measures to protect its website and systems but cannot guarantee that electronic communications or online systems will be completely secure.

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18. Limitation of Liability

To the maximum extent permitted by applicable law, LUGEN shall not be responsible for losses arising from:

• reliance on general information published on the website;
• investment or business decisions made by users;
• changes in market conditions;
• inaccurate or incomplete third-party information;
• interruptions or technical failures;
• temporary unavailability of the website;
• third-party websites or services;
• unauthorised access caused by circumstances outside LUGEN’s reasonable control;
• events beyond LUGEN’s reasonable control.

Nothing in these Terms excludes or limits liability where such exclusion or limitation is not permitted by applicable law.

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19. Indemnification

To the extent permitted by applicable law, you agree to indemnify and hold harmless LUGEN, its directors, officers, representatives, employees and authorised service providers from claims, losses, liabilities, damages and reasonable expenses arising from:

• your unlawful or unauthorised use of the website;
• your violation of these Terms;
• your violation of applicable laws or third-party rights;
• information or materials submitted by you that infringe the rights of others;
• your misuse of information or materials obtained through the website.

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20. No Waiver

If LUGEN does not immediately enforce any provision of these Terms, this does not constitute a waiver of LUGEN’s right to enforce that provision or any other provision in the future.

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21. Changes to These Terms

LUGEN may update or modify these Terms from time to time to reflect changes to:

• the website;
• LUGEN’s services;
• investment opportunities;
• business activities;
• technology;
• applicable requirements.

The updated version will be published on this website and identified by its “Last Updated” date. Your continued use of the website following publication of updated Terms constitutes acceptance of the updated Terms to the extent permitted by applicable law.

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22. Governing Law

These Terms shall be interpreted and applied in accordance with the laws applicable to LUGEN HORIZON S.A., subject to any mandatory laws or rights that may apply to users in their respective jurisdictions.

Nothing in these Terms is intended to deprive a consumer or other protected person of mandatory rights that cannot lawfully be excluded.

Where a specific investment, service, partnership or transaction is governed by separate written documentation, the governing law and dispute-resolution provisions contained in that documentation shall apply to that specific relationship.

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23. Severability

If any provision of these Terms is found to be invalid, unlawful or unenforceable, that provision shall be interpreted or modified to the extent necessary to make it enforceable where permitted, and the remaining provisions shall continue in effect.

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24. Entire Agreement

These Terms, together with the Privacy Policy and any additional terms expressly applicable to particular services, opportunities or transactions, constitute the terms governing your use of the LUGEN website. Specific written agreements may contain additional or different terms that apply to the relevant transaction or relationship.

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25. Contact

If you have any questions regarding these Terms & Conditions, please contact:

LUGEN HORIZON S.A.
Vía España 1280, Edificio Orión, Suite 7D
Panamá, República de Panamá

Email: info@lugenhorizon.com

WhatsApp: through the WhatsApp Business contact available on the LUGEN website.

© 2026 LUGEN HORIZON S.A. All rights reserved.